In U.S. v. Campbell, No. 06-12578 (Jan. 3, 2007), the Court held that U.S. v. Jones, 899 F.2d 1097 (11th Cir. 1990) applies to supervised release revocation proceedings, and that accordingly a district court after imposing sentence should elicit fully-articulated objections to the court’s findings of facts and conclusions of law, and the manner in which the sentence was imposed.
At the conclusion of Campbell’s supervised release revocation proceedings, after imposing a 24 months sentence, the district court simply asked "Is there anything further?" The Court never discussed the advisory Guidelines during the proceeding.
The Court vacated the sentence, finding that the district court had failed to elicit objections to the sentence, and that based on the record the Court could not determine whether the district court had considered the range established under the Guidelines. The Court therefore also could not determine whether the sentence was reasonable, and vacated the sentence and remanded the case for resentencing in accordance with Jones.